Santee River Hardwood Co. v. Commissioner
United States Tax Court
1. Claim for relief under section 722 (b) (4) and (b) (5) denied, where petitioner failed to establish that its base period net income was an inadequate standard of normal earnings because of allegedly unfavorable terms of a contract under which it operated until near the end of the base period. 2. Petitioner's claim for relief under section 722 (b) (5), based upon disparity between depreciation deductions in base period years and taxable year, denied.
1Opinion of the Court
OPINION.
PiERCE, Judge:
Petitioner’s principal contention is that it qualifies for relief under subsection (b) (4) of section 722, or in the alternative, under subsection (b) (5). In support of this contention, it presents a threefold argument: First, that during most of the base period it was compelled, by the terms of the Santee contract, to pay abnormally high prices for stumpage, and that this had a depressive effect on its base period earnings; second, that toward the end of the base period, it changed the character of its operations by terminating the Santee contract and purchasing the…
2Cases cited6 opinions
- Wisconsin Farmer Co. v. CommissionerUnited States Tax Court · 1950
- Granite Constr. Co. v. CommissionerUnited States Tax Court · 1952
- Clinton Carpet Co. v. CommissionerUnited States Tax Court · 1950
- Clermont Groves, Inc. v. CommissionerUnited States Tax Court · 1952
- Austin Co. v. CommissionerUnited States Tax Court · 1954
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Santee River Hardwood Co. v. CommissionerUnited States Tax Court · 1956